Episode 324 -- Third-Party Risks and Sanctions Compliance
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
Understanding the Additional Risks When Making a Ransomware Payment
Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more
While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more
Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment. Additionally, companies may maintain parallel sales activities in markets between their...more
As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more
We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more
The cryptocurrency industry has a target on its back – and perhaps justifiably so. The SEC, CFTC and OFAC have been bringing a number of regulatory enforcement actions, including against Bittrex, Inc. ($24,280,829.20 in...more
Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations....more
OFAC announced only one settlement in the first three months of 2023. Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable. The...more
On March 30, federal regulators announced that Wells Fargo Bank had entered into settlements in which it agreed to pay $97.8 million in fines for enabling sanctions violations between 2010 and 2015. In two separate...more
As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
In this webinar, experts from K2 Integrity, C4ADS, and the Anti-Corruption Action Centre will discuss the current Russian sanctions environment, the ways data is being used to identify and track assets of sanctions targets,...more
Facing the myriad third-party sanctions risks can be daunting. Many global organizations rely on a network of third-party intermediaries that pose a variety of risks. To mitigate those risks, companies have to implement...more
If there is one issue that is repeated over and over (and over), it is third-party risks. Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world. And with this enforcement...more
The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more
When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern....more
ANTICORRUPTION DEVELOPMENTS - New Guilty Plea in College Admissions Scandal - On April 21, 2020, Jorge Salcedo, a former tennis coach at a prominent California university, entered into a plea agreement related to his...more
Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more
Even the mighty can fall – Apple agreed to pay OFAC $467k for violations of the Foreign Narcotics Kingpin Sanctions regulations. In 2008, Apple entered into an applications development agreement with SIS, a Slovenian...more